ML20049J190

Specification of Changes Required in Emergency Planning Per ASLB 800118 Order & 820301 Stipulation.Certificate of Svc Encl

ML20049J190
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	03/09/1982
From:	Semmel H, Wiktor D BIER, MILLS, CHRISTA-MARIA, ET AL
To:
References
ISSUANCES-OLA, NUDOCS 8203120243
Download: ML20049J190 (7)

Text

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00'iETF r-UNITED STATES OF AMERICA

• p li,R -9 P3 :34 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Docket No. 50-155-OLA

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Consumers Power Company

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(Spent Fuel Pool

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(Big Rock Point Nuclear Power Plant

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Modification) 9!

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R GcOYVED-3 Q.

gIAR I ?7 INTERVENORS SPECIFICATION OF C

e CHANGES REQUIRED IN EMERGENCY PLANNING

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2A Q UNDER CHRISTA - MARIA CONTENTION NO. 9 s

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Christa-Maria Contention No.9 as reworded by the Board, provide:

The expansion of the spent fuel pool requires a change in the emergency plan to take into account the significant increase in the radioactive spent fuel that will be stored at the site.

Pursuant to the Order Following Special Prehearing conference dated January 18, 1980 (pp.19-20) Intervenors hereby specify the changes required in the emergency plan because of increased fuel storage.

Current emergency planning does not take into account the change in the type of fuel the plant was designed for and the change in fuel storage to recycle plutonium.

Big Rock specific fuel 8203120243 82O309 f

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inventory, especially the unusual amount of MOX fuel being processed on site, changes assumed emergency planning in the envent of:

1)

Breach of Containment.

2)

Reacter Steam Explosion and its effects upon the spent fuel pool and containment isolation.

J An increase in the spent fuel pool and thereby an increase in ex) fuel inventory at the Big P.ock Point Facility will exacerbate problems with current emergency planning.

The plan is based on a theory of minimal releases.

It does not take into account large releases of radioactive material such as would occur from a hydrogen steam explosion of the expanded spent fuel pool or breach of containment from, for instance, a plane crash.

Breach of containment with an expanded pool would allow a higher fuel inventory to escape and therefore endanger the-public in ways emergency planning is currently inadequate to handle.

"The increased quantity of plutonium in the Big Rock Point core introduces the possibility that core nuetronics are afflicted infavorably or that the increased toxicity of plutonium results in an unacceptable increase in radiation doses to the public during normal or post accident conditions."

U.S. Atomic Energy Commission Docket No. 50-155 December 6,1972, Memo of James Shea, p.4.

There is nothing in the current emergency plan that emphasizes gamma radiation.

The current plan is the same standard emergency plan for all nuclear plants of its size.

It is used whether or r.ot the plant has sheilding.

Proper sheilding would sheild gamma rays.

This problem of gamma ray exposure will be exacerbated by an increase in the spent fuel pool.

There is a need to better

educate the public and local officials on gamma ray radiation and to incorporate possible gamma ray exposure into the emergency plan.

An area not specifically dealt with in current emergency planning and public information programs is the high susceptibility to radiation that children and pregnant women have.

In light of the possible faster rate of release of radiation at higher dose levels from an expanded fuel pool, combined with the MOX fuel, this is an area that especially must be dealt with fast growing cells such as those of children and fetus' are very susceptible to radiation.

Children and pregnant women should be evacuated at much lower levels of radiation than in the current planning for the general public.

Earlier evacuation would afford greater protection to these highly vulnerable segments of the population.

The current monitoring, as set up, does not afford sufficient protection to the public.

In some areas equipment is inadequate.

There are measurements which are done'by extrapolation whose accuracy even in a minor event is not desirable.

These inaccuracies will merely be increased when the dose rates and release rates of radioactive hx:reas3.

There is a need for more accurate monitoring.

l There is a need for more training of personnel on the local level The " manpower / equipment plans as set up are not functioning plans in reality, a problem which is pervasive in all the " manpower" plans.

l The plans show to have certain people for certain jobs.

In reality some of those people don't exist, either they are no longer around or they no longer do that job.

The practice exercise also showed f

there to be poor coordination between personnel doing various jobs.

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The Big Rock Point area has high evacuation times compared to i

l other plants (5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in the summer, 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in the winter) and a number of days during the year where evacuation is impossible due I

y the elements.

This time frame needs to be taken into account in emergency planning in light of the MOX fuel ani the proposed incrpase in the inventory of radioactive material.

Current planning is based on the mega watt of the power plant, not the fucl inventory.

The increase radiation from MOX fuel and an increase in the spent fuel pool will release higher doses of radiation at a faster rate in the event of an emergency than is currently being planned for.

Due to higher radiation releases at a faster rate and the long evaluation time, changes in time sequences in emergency planning, are recommended:

1.

Notify the public at the beginning of radiatica' releases I

rather than waiting for the situation becomes critical. 'This,.could afford persons a chance to leave at an earlier time s'ich as parents with children or pregnant women.

This would also afford notice to persons in the area that they may need to begin preparation for evacuation This would, in effect, be similar to the Weather Bureau's " watch" and " warning" alerts for hurricanes 'and tornados.

2.

Evacuation should begin at an earlier time at lower radiation doses due to the faster increase in radiation levels and the current long times for evacuatio,n.

3.

There should be sep'arate plans'for winter and summer which take into account a) the extraordinarily long time and difficulty of winter evacuation and b) the vagt fluctuations in population that

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occur seasonally and the substantially higher numbers of people that

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are in the Big Rock point area in the summer tine.

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There are deficiencies in communications between the plant and the stato emergency operating center.

There are deficiencies in communications to the public at large.

trre is a -need to better educate thepublic, local officials

' and school officianls as to the dangers of radiation exposure, what

'actions that need to be taken to minimize exposure and what should be done in the event of an emergency.

The current public information pamphelets are allowed to be distributed without editing or approval from the NRC and are grossly inadequate.

Respectfully submitted, On the memorandum:

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'h) v Denise Wiktor Herbert Semmel Legal Intern Attorney for Intervenors Christa-Maria, Mills and Bier

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CERTIFICATE OF SERVICE i

I certify that copies of the foregoing Intervenors Specification of Required Changes in Emergency Planning were served on the attached list on the 9

• ' day of March, 1982 by delivering copies to the office listed thereon or by U.S. mail, first class postage prepaid.

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AttorneyforInt(ervenors Herbert Semmel Christa-Maria, Mills and Bier l

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.it Safety and Licensing Jersp? Calle, Enquire E:ard Pane")

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U.S.

Nuclear Regulatory 1120 Cor.necticutt Ave.

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ssien Suite 325 Washingte..,

D.C.

20555 washington, D.C. 20036 i

. Esq., Chairman Peter B.

Bloch, Atomic Safety and Licensing

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Board Panel U.S. Nuclear Regulatory

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Commission Washington D.C.

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Dr. Oscar H. Paris Atomic Safety and Licensing

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Board Panel

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U.S. Nuclear Regulatory DggketingandServiceSection Commission O..

ce of the Secretar Nuclear Regulator ("-

Washington D.C.

20555 U.S.

Commis s ion Mr. Fredrick J. Shon Washingten, D.C.

20555 Atomic Safety and Licensing

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John O'Neill, II Bobrd Panel Ecute 2, Bcx 44 U.S. Nuclear Regulatory Maple City, MI 49664 Commission Washington D.C.

20555 Janice E.

Moere, Esq.

Counsel for NE: Staff U.S. Nuclea r Re gulatory Corr.:ssion Washincton, D.C.

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